Effective Date: 25 May 2024
1. Introduction
Finatal (“we,” “our,” “us”) is committed to protecting your privacy.
Candidate
This Privacy Notice applies to you if you are a candidate who is looking for a permanent, temporary or contract position. It also applies to you if you were introduced to one of our clients or if you have been engaged by us as a worker, work-seeker or contractor.
Client or business representative
This Privacy Notice is relevant to you if you are a representative of one of our (prospective) clients, suppliers or business partners.
This Privacy Notice outlines how we collect, use, and protect your personal information when you visit our website https://finatal.com (the “Website”) and interact with our business.
The following Finatal entities process your personal data:
| Dajaroo Limited T/A Finatal | C/O Hillier Hopkins, Radius House, 51 Clarendon Road, Watford, Hertfordshire, United Kingdom, WD17 1HP | United Kingdom |
| Finatal GmbH | Lyoner Strasse 14, 60528 Frankfurt am Main, Germany HRB 126638 | Germany |
| Finatal Inc | A Delaware corporation with principal place of business at 1140 Avenue of the Americas, New York, NY 10036 EIN: 88-4190171 | United States |
In the United Kingdom, Finatal is registered with the Information Commissioner’s Office, under certificate number Z2364438.
Your personal data may be shared, stored and processed outside the European Economic Area (EEA). We will only transfer your data outside of the UK and the EEA to countries which both the UK and the European Commission believe offer an adequate level of protection to you or where appropriate safeguards have been put in place to preserve the privacy of your data.
If we process your personal data, we mostly rely on the following legal bases:
| Legal basis | Example |
| Legitimate interest | Adding your details to our database and contacting you from time to time to discuss current business affairs and potential (job) opportunities for you or your business. Sending emails for marketing purposes if you are an existing client. |
| Contract | Signing an agreement with your organisation. |
| Legal obligation | Under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, we must retain evidence of a candidate introduction or supply for at least one year from the last activity e.g., interview, introduction or engagement. |
| Consent | Sending emails for marketing purposes if you are a prospective client or forwarding your resume to one of our clients if you are a candidate. |
The legal basis on which we usually rely for processing your information will be our legitimate interests. We have carried out a Legitimate Interest Assessment which is available upon request.
As part of this Legitimate Interest Assessment (‘LIA’), a “balancing test” is carried out to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests.
2. Information We Collect
We collect the following types of personal information from you through our website:
Personal Information: When you fill out a form or upload your CV, we may collect your name, email address, phone number, address, employment history, education history, and any other information you choose to provide.
Technical Information: We may collect information about your device and browser, including your IP address, browser type, operating system, and referring URLs. For more information, see our Cookies Policy.
If you are considered for a permanent or interim role, we may also collect the following information:
- A copy of your passport/ visa
- National Insurance or equivalent number
- P45, P46 or equivalent document
- Company documents (see explanation below)
For enhanced screening or compliance purposes, we may also ask you to provide us with additional documentation. If this is the case, then we will tell you what documents we need.
We may have to collect documents which may relate to you as an individual, including information relating to any limited company directorship or shareholdings you have (e.g. your company, this can be your own limited company or a nominated umbrella company), certificate of incorporation, proof of tax & social security status, VAT certificate (when applicable), proof of bank details, insurance documents and where applicable statutory information (e.g. IR35 status).
Furthermore, we will process your assignment details (including the agreed rates) and provide you with a Key Information Document to give you visibility on how your take-home pay is calculated if you are seeking temporary or contract work.
If you want to know exactly what documents we hold on file about you, please contact your recruitment consultant or email dataprivacy@finatal.com.
3. How do we obtain your information?
Directly from you.
For example:
the information you provide to us while searching for a new opportunity
the information provided to us during the different stages of the recruitment process.
From an agent/third party acting on your behalf.
For example:
another recruitment business
Through (publicly) available sources.
For example:
Job boards (for example Linkedin, Reed online, Freelance.de Milkround)
your organisation’s website
By reference or word of mouth.
For example:
you may be recommended by a friend, a former employer, a former colleague or even a present employer.
If you want to know how we acquired your details, please speak to your recruitment consultant or email dataprivacy@finatal.com
4. How We Use Your Information
Candidates and Client representatives
We may use your information we collect to:
- Process and evaluate your job application and match you with potential job opportunities.
- Communicate with you regarding your application, job opportunities, assignments, placements, interests and insights that may be of interest and wider enquiries.
- Improve our Website and services.
- Pay you or your business for any work performed for our clients
- Provide you or your business with talented candidates
- Invoice you your business for any work performed by our contractors
- Comply with our contractual and legal obligations and protect our rights.
5. Sharing Your Information
We may share your personal information with:
Potential Employers: To match you with job opportunities and submit your application. We will only provide our clients with your details provided that we receive your prior written consent for doing so.
Service Providers: Third-party service providers who assist us in operating our website, our database and providing our services.
Legal Authorities: If required by law or to protect our rights.
Umbrella companies: We may share your personal details with an umbrella or management company if you have confirmed a desire to utilise an umbrella company that is on our preferred supplier list.
6. Data Security
We take appropriate measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction.
We process your personal data through reputable service providers. Our CRM database is called Bullhorn. For more specific information on how your data is secured on Bullhorn, please see Privacy Policy – Bullhorn UK.
7. Data Retention
In most circumstances your information will not be retained for more than six years from the last point at which we provided any services or otherwise engaged with you.
It is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.
The following sets out the lengths of time we are required by law to retain your data or certain elements of your data:
- for 12 months from the date we last provided our recruitment services to you for the purposes of providing evidence of the recruitment services we provided to you (Regulation 29 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003);
- for two years from the end of your last period of engagement or employment for the purposes of providing evidence that right to work checks were carried out under The Immigration (Restrictions of Employment) Order 2007;
- for three years from the end of the relevant year for the purposes of any parental/adoption leave records or statutory maternity or paternity pay; and
- for six years from the end of each tax year for the purposes of retaining payroll records under the Income Tax (Employment and Pensions) Act 2003,
- for six years from the end of each tax year for the purposes of keeping VAT records for any VAT registered limited company contractors.
However, we may retain data for longer than a six year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where your personal information identifies specialist skill sets which may remain in demand, where there is an ongoing relationship between you and Finatal, or where we are subject to a legal obligation which applies for a longer period.
If, however, you believe that we should delete your personal data at an earlier date, please let us know by emailing dataprivacy@finatal.com.
8. Your Rights
By law, you have a number of rights in relation to your personal data. For more information see below.
| Rights | What does this mean? |
| 1. The right to be informed | You have the right to be provided with clear, transparent and easy to understand information about how we use your data and what your rights are. This is why we are providing you with the information in this Data Privacy Notice. |
| 2. The right of access | You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Notice). If you would like to make a request for information, please contact dataprivacy@finatal.com. This is so you are aware and can check that we are using your information in accordance with the GDPR. |
| 3. The right to rectification | You are entitled to have your information corrected if it is inaccurate or incomplete. |
| 4. The right to erasure | This is also known as ‘the right to be forgotten’ and in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. |
| 5. The right to restrict processing | You have the right to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but cannot use it further. We keep encrypted lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future. |
| 6. The right to data portability | You have the right to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT system and theirs safely and securely, without affecting its usability. |
| 7. The right to object to processing | You have the right to object to certain types of processing, including processing for direct marketing (e.g., if you no longer want to be contacted regarding potential opportunities). |
| 8. The right to lodge a complaint | You have the right to lodge a complaint about the way we handle or process your personal data with the ICO https://ico.org.uk. |
| 9. The right to withdraw consent | If you have previously given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes. |
Further information and advice about your rights can be obtained from the Information Commissioner’s Office. https://ico.org.uk/.
To exercise these rights, please contact us at dataprivacy@finatal.com. We will respond any request within one month (this can be extended to two months in exceptional circumstances).
However, where requests are manifestly unfounded or excessive in particular because of its repetitive character, we may refuse to act upon your request. If this happens then we will inform you within one month of about the possibility of lodging a complaint with a supervisory authority or seeking a judicial remedy.
Submitting a deletion request does not necessarily mean that we will grant your request in every instance especially if we have good reasons to retain your personal data. We will always give reasons if we decline your request.
9. Automated processing
We will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you. We will furthermore not analyse or predict aspects concerning your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
10. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience on our Website. For more information, please refer to our Cookie Policy.
11. Third-Party Links
Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of these websites. We encourage you to read the privacy notices of any third-party websites you visit.
12. Changes to This Privacy Notice
We may update this Privacy Notice from time to time. The effective date of the revised Privacy Notice will be indicated at the top of the page.
Contact Us
If you have any questions or concerns about this Privacy Notice, please email or contact us at dataprivacy@finatal.com. This does not affect your right to make a complaint to the Information Commissioner’s Office.
